Cash Dividends to Be Remitted to US-domiciled Company Subject to 15% Withholding Tax

September 6, 1985 BIR RULING NO. 157-85 24 (b) (1) (iii) 258-82 157-85 Gentlemen : This refers to your letter dated August 30, 1983 requesting a ruling from this Office that the cash dividends which you will remit to your American shareholder, the Manila Manufacturing Company of West 57th Street, New York, New York U.S.A., are subject to withholding tax at the rate of 15%. It is represented that the recipient corporation is a non-resident foreign corporation not engaged in trade or business in the Philippines, owning 99% of the outstanding capital stock of Avon Products Mfg. Inc. (formerly Aura Laboratories, Inc.), a domestic corporation. In view thereof, and considering that under the present provisions of the U.S Federal Tax Code, the amount of tax deemed paid of such dividends, and accordingly, to be credited against the U.S. that on said dividends meets the 20% requirement of Presidential Decree No. 369, this office hereby certifies that the cash dividends which you will remit to Manila Manufacturing Company domiciled in the United States are subject to withholding tax at the rate of 15% duty, pursuant to Section 24(b)(iii) of the Tax Code, as amended. cdtech Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner